Suprise 75 Year Old Tank Had Been Leaking For Some Time

from a West Virginia Gazette U-tube video

For over days in the middle of last January 2014 Charleston, West Virginia and the surrounding communities were without drinking water due to contamination from a chemical leak. A former fuel storage tank that was being used to store MCHM had released about 10, 000 gallons of MCHM into the Elk River just a mile and a half up river from the water intake for the drinking water supply for Charleston. The chemicals were 4-methylcyclohexanemethanol (MCHM) mixed with 5.6% propylene glycol phenyl ethers (PPH). MCHM is an alcohol with a licorice or mint smell at extremely low concentrations, and though there are limited studies, it is believed to have relatively low toxicity. Both MCHM and PPH have known human health effects including skin, eye, and respiratory tract irritation. According to the Center for Disease Control and Prevention, CDC, drinking water contaminated with concentrations less than 10 parts per billion MCHM is safe. However, the limited studies done on MCHM were small short term studies on acute exposure as might happen with a chemical worker in an industrial setting, not a large population drinking and bathing in water contaminated with low levels of MCHM.

The chemical storage facility was owned by a private company, Freedom Industries, Inc., now bankrupt due to this incident. The site of the leak was once a Pennzoil-Quaker State gasoline and diesel storage terminal that was sold in 2001 and had recently been acquired by Freedom Industries. These 75 year old tanks were put to new use storing chemicals. Though it was common in the past to have fuel storage tanks on rivers, it was not the safest of ideas. However, when the facility was built in 1938 the fuel arrived by barge and the drinking water intake was not there. When Pennzoil-Quaker State closed the facility and sold it, the new owners (and apparently the state regulators) though it was okay to store solvent in a series of old 48,000 gallon above ground riveted storage tanks that clearly had inadequate secondary containment to prevent a spill into the river. It is to be noted that there were also other larger storage tanks at this site. This was all legal. There are very limited requirements for secondary containment on ASTs and no lifetime limits on equipment age. There are no state requirements for routine inspections for condition of equipment or adequacy of containment. Even at the time of the most recent sale there was an inappropriate level of due diligence performed to evaluate the risk.

Last week workers began dismantling the facility, but not before the Chemical Safety Board (CSB) had performed an investigation of the site. Jonnie Banks the team leader for the CSB reported their findings at a public meeting in Charleston, West Virginia. The CSB’s forensic inspection of the tanks on site found three tanks had been used to store MCHM, not just the tank that was the source of the observed leak last January. In draining the tanks the CSB found MCHM in three tanks despite incorrect paperwork. Extensive corrosion and pitting was found in all three tanks, two of the tanks already had holes. The largest hole found in the preliminary report was in the tank with the observed leak, but at least one of the other tanks had been leaking.

In their preliminary report, the chemical safety board found that the tanks had been leaking for an extended period of time that has not yet been estimated. Until the soil under all three tanks is tested it will not be definitively known the extent of the chemical release. Once the extent of the contamination is determined, and then computer modeling of the release needs to be performed so that better health impact studies can be performed. However, as the CSB pointed out there may not be adequate toxicology data on MCHM for an adequate determination of the long term safety of the drinking water supply though, American Water has not detected any MCHM in any of their most recent tests. Depending on the results of the computer modeling and the level of remediation required by the regulators, the residents of Charleston may turn out to be a study on long term low level exposure to MCHM.

The obvious cause of this chemical contamination of the Charleston drinking water was time and the failure to maintain and improve our infrastructure over time. Over 75 years the chemical tanks pitted and corroded and simply wore out and began to leak. There were inadequate regulations to ensure regular (or any) engineering inspections documenting the condition of the tanks. The U.S. Environmental Protection Agency does not regulate most aboveground fuel storage tanks (AST) and there are no national standards for secondary containment and spill prevention. In addition, there are no regulations that limit the maximum life that a tank can continue to be used. This endangers our rivers, watershed and groundwater. Unless you have a permit to discharge to surface waters you are not required to have a spill prevention plan, but clearly these tanks had inadequate secondary containment. All fuel and chemical storage tanks whether aboveground or underground should be required to have adequate secondary containment and spill prevention plans.

Over time the tanks grew old and failed. Over time the industry standards for secondary containment changed, and the containment for these tanks was no longer up to industry standards nor adequate. Over time the city of Charleston grew and the water intake for the drinking water supply for the city was built within 1.5 miles of an old and operating chemical plant. Mr. Banks of the CSB was right when he asked how this happened. At least the public water supply should have performed a risk assessment of their raw water source, but that would have cost money for the rate payers and we like our water and sewer systems to be as cheap as possible. We assume safe, but we fail to maintain and improved our infrastructure.

Separately, in the U.S. Bankruptcy Court in Charleston last Tuesday the creditors and insurers for Freedom Industries failed to reach an anticipated $2.9 million settlement in the 24 lawsuits against Freedom Industries. The company declared bankruptcy in January after the chemical release and contamination of the drinking water supply was discovered. For excellent coverage of this incident see the West Virginia Gazette  17 minute video and the work of Ken Ward, Jr.

Turning One Environmental Disaster into Two

For over a week in the middle of last January Charleston, West Virginia and the surrounding communities were without drinking water due to contamination from a chemical leak. A former fuel storage tank that was being used to store MCHM had released about 10, 000 gallons of MCHM into the Elk River just a mile and a half up river from the water intake for the drinking water supply for Charleston. MCHM is 4-methylcyclohexylmethanol an alcohol with a licorice or mint smell at extremely low concentrations, and though there are limited studies, it is believed to have relatively low toxicity.

When the MCHM leak was first discovered the West Virginia Department of Environmental Protection, DEP, found the MCHM above ground storage tank with a hole in it sitting within an unlined concrete block containment dike. The MCHM leaked from the tank into an unlined cinderblock containment area and then into the ground through which it began leaching into the Elk River and flowing about a mile down to the Charleston West Virginia water intake for the American Water drinking water treatment plant. The drinking water plant is not designed to remove the chemical from river water, so the “finished” water had the tell tail smell. It is not reassuring to be told that it has low toxicity when you can smell chemical contamination in your drinking water.

During the cleanup by Freedom Industries, the owner of the storage tank facility, about 700 tons of Crude MCHM-mixed with wastewater and sawdust to solidify it was removed from the site. Contaminated soil was left in place. Freedom Industries brought the MCHM contaminated waste to a sanitary landfill in Hurricane West Virginia. The landfill was owned and operated by Waste Management. In February 2014, without notifying the town of Hurricane, the West Virginia DEP Division of Water and Waste Management approved a request for a “Minor Permit Modification” to allow Waste Management to accept the wastewater at their Hurricane landfill. The permit modification granted at the time would allow the landfill to accept the MCHM, water and sawdust mixture until October of 2014.

On March 12, 2014 Inspectors from the West Virginia DEP responded to “licorice” odor complaint at the landfill in Hurricane. According to the DEP it was determined that the odor was from the approved disposal of wastewater that was being transferred to the landfill. Putnam County and the city of Hurricane, West Virginia petitioned a Kanawha County circuit judge who granted a preliminary injunction blocking the DEP from allowing Waste Management to continue to dispose of the MCHM-sawdust mixture at the landfill. By the March 15th hearing, the West Virginia DEP had modified the permit once again so that the permission to accept the MCHM contaminated waste had expired.

By all accounts about 228 tons of MCHM, wastewater and sawdust mixture was buried at the Hurricane Landfill. Now Hurricane is suing Waste Management to remove the material from the landfill because they are concerned that the MCHM will leach out of the landfill into the landfill collectors that go to a waste water treatment plant that ultimately releases to a creek that feed the Kanawha River, the source of Hurricane’s drinking water supply. The waste water treatment plant is not designed to remove MCHM from the leachate. The rest of the 700 tons of MCHM contaminated material from the original Freedom Industries site was ultimately disposed of at a hazardous waste disposal well in Vickery, Ohio.

Waste Management wants the case dismissed on a technicality and because the MCHM sawdust mixture does not meet the definition of hazardous waste under the Federal Resource Conservation and Recovery Act and the disposal was done under permit.

MCHM will continue to appear in the Charleston drinking water as it continues to leach into the Elk River from the contaminated soil that remains at that site. A month after the first incident in Charleston, MCHM was once more detected in the cities’ water supply and forced a closing of Charleston schools. Now Hurricane, West Virginia is waiting for MCHM to appear in their drinking water supply.

These rivers are the source of the drinking water supplies for over 300,000 people, old, young, healthy, sick, and pregnant- the entire spectrum. Now, there is the potential that both communities with have their drinking water impacted by chronic long term extremely low level exposure to MCHM for years. These were absolutely the wrong decisions. Public concern is very real, whether or not the MCHM mixture meets the definition of hazardous waste. That sawdust mixture should have been incinerated for a permanent solution and the tank or tanks should have been removed from the Freedom Industries site and along with all the contaminated soil to be remediated at a different site away from a drinking water supply. Moving contamination from one site to another is not remediation. Incineration, remediation or disposal at a hazardous waste disposal site would have been far more appropriate than using the town sanitary landfill. In the United States the purity of our public water supplies is sacred.

In Charleston they Need to Investigate and Remediate

For about a week in the middle of January Charleston (and the surrounding communities) was without drinking water when a leak was discovered in a former fuel storage tank that was being used to store MCHM. By all accounts about 10, 000 gallons (previously estimated at 7,500 gallons) of MCHM was released into the Elk River a mile and a half up river from the water intake for the drinking water supply for Charleston, West Virginia. MCHM is 4-methylcyclohexylmethanol an alcohol with a licorice or mint smell at extremely low concentrations, and though there are limited studies it is believed to have relatively low toxicity. Now a month later, MCHM has been once more detected in the water supply and forced a closing of Charleston schools. The New York Times reports a “Crisis of Confidence,” “emotional public meetings,” and politicians and the U. S Environmental Protection Agency “listening” and “sharing” the public’s concern.

When the MCHM leak was first discovered the West Virginia Department of Environmental Protection, DEP, found a MCHM storage tank with a hole in it sitting within an unlined concrete block containment dike. The DEP inspectors noted a 4 foot wide stream of liquid flowing across the dike and into the ground. So here’s what happened, the MCHM leaked from the tank into an unlined cinderblock containment area and then into the ground through which it began leaching into the Elk River and flowing about a mile down to the Charleston West Virginia water intake for the American Water drinking water treatment plant. MCHM will continue to appear in the drinking water as it continues to leach into the river until the site is remediated.

Governor Earl Ray Tomblin, the state and federal regulators, the water company need to do a little less talking and listening and a little more remediation. This is the drinking water supply for 300,000 people, old, young, healthy, sick, and pregnant- the entire spectrum and the drinking water supply is a potential chronic long term low level exposure to MCHM for years. Ultimately they will end up taking steps to address the public concern, do it now. It is an inelegant solution, but a quick one to remove the tank or tanks and dig up and remove all the contaminated soil to be remediated at a different site away from a drinking water supply. Though in most instances, I would not recommend excavate and haul for a remediation approach because it simply moves a contamination problem, in this instance that is what should be done for the public good, peace of mind of the entire community and safety and security of the water supply. Move all the soil contaminated with a moderately toxic substance away from the drinking water supply. When dealing with a drinking water supply and public concern, a brute force and fast cleanup might be the best answer. Worry about cost and liability later; restore the water supply and the public’s trust in the ability to supply reliable and pure water.

The chemical storage facility is owned by a private company, Freedom Industries, Inc. that primarily appears to distribute chemicals. The site of the leak was once a Pennzoil-Quaker State gasoline and diesel storage terminal that was sold in 2001. These old tanks (reportedly installed around 1938) were apparently put to new use storing chemicals. Though it was common in the past to have fuel storage tanks on rivers, it was not the safest of ideas; however, the fuel arrived by barge. When Pennzoil-Quaker State closed the facility and sold it, the new owners though it was okay to store MCHM in an old 35,000 gallon above ground riveted storage tank that clearly had inadequate secondary containment to prevent a spill into the river. This was all legal, but it should not have been. Chemicals and fuel storage tanks both above and below ground should be permitted for a set number of years that is less than the expected life of the containment system. Instead tanks are allowed to remain in use until they fail. In addition, there are very limited requirements for secondary containment on ASTs and no lifetime limits on equipment age. This metal tank was 75 years old.

We as a nation have lost respect for stewardship and engineering. Politics runs the country and businesses. This is what happens when a nation’s infrastructure is not maintained and it is only going to increase. There are hundreds of examples of mechanical, design and structural failure turning up every day, but only the multi-million dollar problems make the news. The EPA needs to stop focusing all their energies on global issues and refocus their attention on maintaining water quality and availability. As a nation we need to focus on maintaining and improving water, sewage, electricity, roads and essential infrastructure in the United States.

Every four years, America’s civil engineers provide a comprehensive assessment of the nation’s major infrastructure categories in ASCE’s Report Card for America’s. Using a simple A to F school report card format, the Report Card provides a comprehensive assessment of current infrastructure conditions based on: capacity, condition, funding, future need, operation and maintenance, public safety, resilience, and innovation. Our grades average Ds, due to delayed maintenance and underinvestment across most categories. We are a nation of infrastructure deniers.

Drinking Water is Restored to Charleston West Virginia

For almost a week Charleston (and the surrounding communities) has been without drinking water. A week ago a leak was discovered in a former fuel storage tank that was being used to store MCHM. By all accounts about 7,500 gallons of MCHM was released into the Elk River a mile and a half up river from the water intake for the drinking water supply for Charleston, West Virginia. The water company originally believed that the plant filter could remove the MCHM which is actually the acronym for 4-methylcyclohexane methanol a modestly water soluble octanol used in air freshener and for washing coal, but the water treatment plant’s filtration is not effective in removing the chemical and they were forced to issue a do not use for drinking, cooking or bathing warning to their water customers.

The chemical storage facility is owned by a private company, Freedom Industries, Inc. that primarily appears to distribute chemicals. The site of the leak was once a Pennzoil-Quaker State gasoline and diesel storage terminal that was sold in 2001. These old tanks (reportedly installed around 1938) were apparently put to new use storing chemicals.Though it was common in the past to have fuel storage tanks on rivers, it was not the safest of ideas; however, the fuel arrived by barge. When Pennzoil-Quaker State closed the facility and sold it, the new owners though it was okay to store solvent in an old 35,000 gallon above ground riveted storage tank that clearly had inadequate secondary containment to prevent a spill into the river. This was all legal. There are very limited requirements for secondary containment on ASTs and no lifetime limits on equipment age . This has been a known problem for decades.

Back in January 1988 about 800,000 gallons of diesel fuel escaped from an Ashland Oil company storage tank that ruptured 20 miles upriver from downtown Pittsburgh. The 40-year-old tank was within a containment dike that reportedly held 2.5 million gallons but failed to stop the overspill from running into the river. The oil spill shut down drinking water for days. The problem then and now is that the secondary containment that was historically used for fuel storage was motivated to prevent fires, not prevent leakage into the river. Diesel and gasoline float and are easier to capture that an octanol, but that is secondary. In many places (and apparently still in West Virginia) the secondary containment was earthen berms without a liner.

Despite the striking reminder from the Pittsburgh incident and others, the U.S. Environmental Protection Agency does not regulate most aboveground fuel storage tanks (AST) and there are no national standards for secondary containment and spill prevention. In addtion, tanks have no maximum life and there are tanks more than 75 years old that continue to be used. This endangers our rivers and groundwater. Unless you have a permit to discharge to surface waters you are not required to have a spill prevention plan. All fuel and chemical storage tanks whether aboveground or underground should be required to have adequate secondary containment and spill prevention plans. There are two types of ASTs: vertical  and horizontal. Horizontal ASTs typically hold from a few hundred gallons up to 20,000 gallons, while the storage capacity of vertical ASTs ranges from several thousand gallons to over 10 million gallons. Nothing is fail safe and these tanks pose a risk to our water supplies that needs to be addressed.

The Safe Drinking Water Act (SDWA) and it various amendments have increased the number of chemicals that they must test for and tightened the standards they must meet, but those have typically addressed chemicals that appear in river water as runoff and from water discharged from waste water treatment plants. Drinking water supplies for cities are typically drawn from rivers which are highly vulnerable to upstream spills and pollution. We need to protect our water resources and drinking water supplies by preventing pollution not just beefing up the water treatment process.